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TMI Blog2022 (5) TMI 1467X X X X Extracts X X X X X X X X Extracts X X X X ..... s 147 to 151 with effect from 1st April, 2021 - HELD THAT:- In the present case, the notice under Section 148 of the Act pertaining to the Assessment Year (AY) 2013-14 was issued on 30th March 2021, i.e., prior to 1st April 2021. Also, it was beyond the period of six years after the expiry of the AY in question. Consequently, both in light of the Judgment of the Supreme Court in Union of India ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s the correctness of the orders passed by the High Courts of Delhi, Rajasthan, Calcutta, Madras and Bombay on the question of the validity of notices issued by the Income Tax Department (Department) under Section 148 of the Income Tax Act, 1961 (Act) in light of the amendment by the Finance Act 2021, which introduced the new amended provisions i.e., Sections 147 to 151 with effect from 1st April, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the Constitution of India so as to avoid any further appeals by the Revenue on the very issue by challenging similar judgments and orders, with a view not to burden this Court with approximately 9000 appeals. We also observe that present order shall also govern the pending writ petitions, pending before various High Courts in which similar notices under Section 148 of the Act issued after 01.04. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... others v. Ashish Agarwal (supra) and the Order of this Court dated 24th January 2022 in W.P.(C) No.20919 of 2021 and batch of writ petitions in M/s. Ambika Iron and Steel Pvt. Ltd. and others v. Principal Commissioner of Income Tax and others, the impugned notice is hereby quashed and all the subsequent orders and proceedings are also hereby quashed. 5. The writ petition is disposed of in the a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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